iHustle Privacy Policy

Welcome to iHustle ("iHustle," "we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our website www.ihustle.app, the iHustle Personal Trainer mobile app (including its companion Apple Watch app and associated widgets), and our services (collectively, the "Platform"). Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Platform.

We take your data protection very seriously and handle it confidentially and in accordance with legal regulations and the following privacy policy. This applies to the "iHustle Personal Trainer" app available in the Apple App Store and our website www.ihustle.app.

Downloading and installing the iHustle Personal Trainer app may require prior registration in the respective App Store. During this process, Apple collects, processes, and uses personal data over which we have no control. The sole party responsible in this regard is the operator of the respective App Store. If necessary, please consult the respective App Store provider directly.

iHustle partially links to external sites and offers. Once these links/offers are accessed, you leave the iHustle offering/service, and the data protection provisions (retrievable) of the external link/offer apply.

Below, we inform you in accordance with Article 13 GDPR about the nature and extent, as well as the purpose of processing personal data (hereinafter referred to as "data") by us. Regarding the terms used, please refer to the definitions in Article 4 GDPR. Personal data includes all data with which you can be personally identified.

1. Who is responsible for processing your Personal Data?

TECHXAI SRL, located in Oradea, Strada Iuliu Maniu, no. 22, Romania, registered with the Romanian Trade Register under no. J05/2032/2022, unique registration code RO46480098, is the "data controller" (i.e., the organization responsible) for all Personal Data collected and used through the Platform, in accordance with applicable data privacy laws, principles, and regulations, including the European Union's General Data Protection Regulation ("GDPR"), the United Kingdom's General Data Protection Regulation ("UK GDPR"), and the California Consumer Privacy Act ("CCPA"). You can contact us at admin@ihustle.app.

2. What Personal Data do we collect?

We may collect and process different types of Personal Data either directly from you through the use of the Platform or from third-party partners or providers.

Identity and Contact Data: first and last names, date of birth, country of residence, email address, profile photo, and, where applicable, phone numbers and billing addresses. This data is necessary to create and manage your user account, verify your identity, and communicate with you.

Authentication Data: your password (stored in protected form), the one-time confirmation codes sent to your email, and, if you choose these methods, the sign-in data provided by Sign in with Apple (name and account identifier) or passkeys. We do not have access to your Apple account password.

Profile and Questionnaire Data: your answers to the onboarding questionnaire and subsequent profile updates — your goal, focus areas, body type, fitness level, previous training experience, fitness test results (for example squats, plank, push-ups), preferred workout location, work routine, and communication preferences — as well as the feedback and ratings you provide after workouts. This data helps us customize the Platform according to your needs.

Health and Fitness Data (special category data): your height, weight history, the health information you provide in the questionnaire (for example heart or blood pressure conditions, breathing conditions, pain, injuries or reduced mobility, blood sugar values, recent pregnancy or postpartum period, and any details you enter in free text), and, with your explicit permission granted through Apple Health, device-generated data: heart rate, active calories, step count, and distance recorded by your iPhone or Apple Watch. This data allows us to offer personalized training recommendations and track your progress. It is processed exclusively on the basis of your explicit consent (Art. 9(2)(a) GDPR).

Progress Photos: the photos you choose to upload to track your body's progress (front, side, back), together with the date they were taken. Uploading photos is always optional.

Workout Activity Data: workouts started, paused, and completed, duration, estimated calories, intensity, perceived difficulty, your notes and feedback, your planned training schedule, and your device's time zone (used to display your schedule correctly).

Community Data: your nickname, bio, community profile photo, the messages and images you post in community channels, reactions, read receipts, and any content you choose to share (for example workout results or progress photos). We also collect content reports and records of moderation measures (restrictions, suspensions) for the safety of the community.

Financial and Transaction Data: for purchases made through the App Store, payment is processed entirely by Apple; we do not receive your card details, only confirmation of your subscription status. For orders placed on our website (where this option is available), payments are processed by an external payment processor; we do not store your full card details. We keep transaction and subscription history for account management and to meet legal obligations.

Nutrition Data: your food diary, water intake, shopping list, favorite meals, and calorie goals. When you scan a barcode, that barcode is sent to the independent Open Food Facts service to identify the product; no other personal data accompanies this request.

Technical and Usage Data: your IP address, login data, operating system and device information, and the technical logs necessary to operate and secure the Platform. The mobile app contains no advertising analytics, cross-app tracking, or commercial profiling tools and does not use the device's advertising identifier.

Location Data: we may derive your general location (for example your country) from your IP address to personalize your experience on the Platform, such as language settings. If in the future you choose to use location-based features (for example recording a running route) and enable location services on your device, we may process your real-time location, only with your permission.

Communication and Social Media Data: information from communications with us through letters, emails, chat services, calls, and social media, as well as data from third-party social media platforms if you choose to interact with us through social media or share content to them (for example Instagram).

3. Why and on what basis do we use your Personal Data?

We process your Personal Data for the following purposes and on the following legal bases:

Providing the Platform (performance of a contract, Art. 6(1)(b) GDPR): creating and managing your account, delivering workouts and progress tracking features, processing subscriptions and orders, syncing data between your devices, and operating the community.

Personalizing workouts and recommendations based on health and fitness data (explicit consent, Art. 9(2)(a) GDPR): your answers to the health questions, data obtained from Apple Health, and your weight history are used exclusively to adapt training and nutrition content to your situation. You may withdraw your consent at any time (see section 7).

Communication (performance of a contract and legitimate interest, Art. 6(1)(b) and (f) GDPR): we use your contact information to communicate with you about your account, updates, and relevant service information.

Customer Support (performance of a contract, Art. 6(1)(b) GDPR): we respond to your inquiries and resolve issues you may encounter.

Marketing and Advertising (consent, Art. 6(1)(a) GDPR): with your consent, we may send marketing communications, newsletters, and promotional offers. You may unsubscribe at any time. Health data is never used for marketing or advertising purposes.

Legal Compliance (legal obligation, Art. 6(1)(c) GDPR): keeping accounting and tax records, responding to requests from authorities, and fulfilling other legal obligations.

Security and fraud prevention (legitimate interest, Art. 6(1)(f) GDPR): protecting the Platform, accounts, and community against unauthorized access, abuse, and illegal activities, including applying community moderation measures.

Improving our services (legitimate interest, Art. 6(1)(f) GDPR): internal statistical analyses, based on aggregated or pseudonymized data where possible, to improve the content and functionality of the Platform.

Surveys and Feedback (consent or legitimate interest, Art. 6(1)(a) and (f) GDPR): we conduct opinion surveys and collect feedback to continuously improve our services.

4. Apple Health and Apple Watch data

If you grant permission through Apple's Health permission system, the app can read data such as heart rate, active calories, steps, and distance, and can record completed workouts. With respect to this data, we commit to the following:

Apple Health data is used exclusively to provide the app's fitness features (displaying your activity, recording workouts, personalizing recommendations).

Apple Health data is never used for advertising, marketing, or commercial profiling, and is never sold or disclosed to data brokers or advertising platforms.

You can revoke the app's access to Apple Health at any time in the Health app or in the Settings of your Apple device, without affecting the other features of the Platform.

5. How do we protect and manage your Personal Data?

Encryption and Security: We implement strict security procedures to protect your Personal Data against misuse, unauthorized access, modification or disclosure, and accidental loss, destruction, or damage. Data transmitted between the app and our servers is encrypted in transit using TLS/SSL technology, and your access credentials are stored on your device in the operating system's secure storage (Keychain).

International Transfers: The Platform's data is hosted primarily on servers located in the European Union. To the extent that certain providers process data outside the European Economic Area, we ensure the transfer takes place on the basis of appropriate safeguards under Chapter V GDPR, such as the standard contractual clauses approved by the European Commission.

Retention of Your Personal Data: We retain your data only as long as necessary to fulfill the purposes for which it was collected. As a guideline: account, profile, and health and fitness data is retained while your account is active and deleted when your account is deleted; progress photos and weight entries can be deleted by you at any time, directly in the app; community messages are retained as long as the relevant channel exists or until removed by you or by moderators; moderation records are retained as long as necessary for the safety of the community; financial and tax records are retained for the period required by applicable tax and accounting legislation (generally up to 10 years). After the retention periods expire, data is deleted or anonymized.

6. Sharing Your Personal Data

We do not sell your Personal Data. We may share your Personal Data for the purposes described in this Privacy Policy with:

Other users of the Platform: content you choose to post in the community (messages, images, nickname, bio, profile photo and, if you so choose, progress photos or workout results) is visible to the other members of the relevant channel.

Service providers (processors) who help us operate the Platform, under data processing agreements: providers of hosting, of infrastructure for the community and chat features, and of media content delivery, with data centers located in the European Union, as well as providers of IT, legal, financial, and marketing support. Upon request, we can provide you with the identity of our current providers.

Apple: for app distribution, In-App payment processing, Sign in with Apple authentication, and, if you grant permission, Apple Health integration, in accordance with Apple's privacy policies.

Providers of features you trigger yourself: Google (Google Cast technology, when you cast a workout to your TV), Open Food Facts (when you scan a barcode), and Instagram/Meta (when you choose to share content to Instagram). These services receive only the data strictly necessary for the relevant feature and are subject to their own privacy policies.

Referral contacts to notify them about your account creation and offer them a referral bonus, if you use such a feature.

Social media platforms when you link your account, participate in events, or use social media plugins, with your consent.

Authorities and regulators to comply with legal requirements and legal advisors to enforce our rights.

Potential buyers in the event of a business sale or transfer, under strict confidentiality agreements.

7. Your Rights and Choices

You have certain rights regarding your Personal Data under applicable data privacy laws. These include:

Right of access: You have the right to obtain confirmation that your Personal Data is being processed and, if so, to access the Personal Data and additional information about its processing.

Right to rectification: You have the right to request the correction of inaccurate Personal Data and the completion of incomplete Personal Data. Most profile data can be corrected directly in the app.

Right to erasure ("right to be forgotten"): You have the right to request the deletion of Personal Data in certain circumstances. You can delete your account and the associated data directly in the app (Profile → Terms & Privacy → Delete Account) or contact us at admin@ihustle.app. Progress photos and weight entries can be deleted individually, at any time, in the app.

Right to restrict processing: You have the right to request the restriction of processing of Personal Data in certain circumstances, for example, if you contest the accuracy of the data or if the processing is unlawful and you oppose the deletion of the data.

Right to object: You have the right to object to the processing of Personal Data at any time, for reasons related to your particular situation, if the processing is based on our legitimate interests. You also have the right to object to the processing of data for direct marketing purposes.

Right to data portability: You have the right to receive the Personal Data you provided to us in a structured, commonly used, and machine-readable format and the right to transmit this data to another controller, if the processing is based on your consent or on a contract and is carried out by automated means.

Right to withdraw consent: You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. For Apple Health data, you can revoke access directly in your device settings; for other consent-based data, you can contact us at admin@ihustle.app. Withdrawing consent for health data may limit the Platform's personalization features.

To exercise any of these rights, please contact us at email: admin@ihustle.app. We will respond to your request within the timeframes provided by the GDPR (generally, one month).

8. Cookies and Other Tracking Technologies

A cookie is a small text file that is placed on your device when you use our website. On the Website we might use cookies and similar technologies to collect information about your preferences and past actions. The iHustle mobile app does not use cookies, advertising analytics, or cross-app tracking technologies.

9. Links to Other Websites

Our Platform may contain links to other websites for your convenience. These websites operate independently and have their own privacy policies, which we recommend you review. We are not responsible for their content, usage, or privacy practices.

10. Children

Users must be at least 16 years old. If you are under 18, you must have parental or legal guardian consent. Individuals are not allowed to sign up for a User Account on the Platform without confirming that they are at least 16 years old. If we identify any User who appears to be under 16, we will contact them to verify their age. If we discover that a person is under 16, we will immediately delete all data held about them.

11. Compliance with the California Consumer Privacy Act (CCPA)

The provisions in this paragraph are intended to fulfill the requirements of the California Consumer Privacy Act ("CCPA") and apply to Users who are California residents.

To the extent any terms used in this Privacy Policy and Supplemental Terms are defined in the CCPA, such definitions will apply. The term "Personal Data" as used in this Privacy Policy and Supplemental Terms will include "Personal Information" as defined in the CCPA.

For the purposes of CCPA, we collect the following categories of Personal Information:

a. Identifiers and Categories of Personal Information Referenced in Applicable California Law: first and last names, email address, country of residence, and social media information when using certain services or features of the Platform.

b. Characteristics of Protected Classifications Under California or U.S. Federal Law: age, country of residence, and the medical conditions or requirements you communicate to us.

c. Commercial Information: information about your purchases of products and services from us or from our third-party partners who may provide or promote their own products or services through the Platform.

d. Biometric and Health Information: physical characteristics such as weight, height, and progress photos, as well as activity data (heart rate, calories, steps) generated by connected devices, if you choose to provide them or grant the corresponding permissions.

e. Geolocation Data: the IP address of your device is used to determine your general geographical location to customize the experience on the Platform (e.g., language settings). If you choose to use location-based features of the Platform and enable location services on your device, we may track your geographical location in real-time to record your fitness activities (e.g., running route).

f. Inferences from Other Personal Data: dietary preferences, information you provide about yourself, and any preferences in your User Account, communications with us or directed to us via letters, emails, chat services, calls, and social media, and physical activity data you provide on the Platform or generated by using the iHustle app (including activity data from devices connected to the iHustle app).

We do not sell your Personal Information. We will not process your Personal Data for purposes that are materially different, unrelated, or incompatible with those set out in the Privacy Policy without providing you with prior notice.

12. How to File a Complaint

We hope that we can resolve any question or concern you may have regarding the use of your information. If you have any issue or concern, please contact us at email: admin@ihustle.app.

In accordance with the General Data Protection Regulation (GDPR), you also have the right to file a complaint with a supervisory authority. In Romania, the supervisory authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP), B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, Bucharest, www.dataprotection.ro. You may also file a complaint in the EU (or EEA) state where you work, normally reside, or where the alleged breach of data protection laws occurred.

13. Changes to This Privacy Policy

A new legal situation or changes in the data processing we perform may require adapting this data protection statement. For this reason, please check our privacy policy content periodically. If a change requires your cooperation (e.g., consent) or another individual notification, we will inform you in an appropriate form.

14. How to Contact Us

If you have any questions or comments about this Privacy Policy, please contact us at email: admin@ihustle.app.

When you contact us, your data will be processed for the management and processing of the contact request. Data transmission is TLS/SSL encrypted, provided your mobile device supports it. This data is processed based on Art. 6(1) of the GDPR. The request/data will be stored in our customer relationship management system or an organization handling requests and will be deleted if no longer necessary.

Thank you for using the iHustle app. We are committed to protecting your privacy and ensuring the security of your Personal Data.